Terms and Conditions

TERMS &  CONDITIONS OF SERVICE

Welcome to Embat’s Platform. The use of Embat’s Platform and the software available on it is authorised under this Licence Agreement by Embat Technologies, S.L., a Spanish company with its registered office at C/ Fuencarral, número 123, 5A, 28010 - Madrid (Spain), registered in the Mercantile Register of Madrid and with the tax identification number B-16808693 (hereinafter, "Embat", "We"), with e-mail address: legal@embat.io. 

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This Licence Agreement constitutes a binding legal instrument between the Client and Embat. Capitalised terms in this Licence Agreement have the meaning set out in clause 21 "Definitions". The contracting of services by the Client shall be formalised by means of a Purchase Order. The Purchase Order is an inseparable part of this Licence Agreement. In the event of any inconsistency between the Purchase Order and the Licence Agreement, the Purchase Order shall prevail.

1. Subject matter and scope of the licence

1.1 The purpose of this Licence Agreement is to set out the terms and conditions under which Embat will provide certain Services to Client.‍

1.2 Embat shall provide the Services by giving the Client (and Users) access to the Platform. For these purposes, Embat grants the Client a non-transferable, non-sublicensable, non-exclusive licence to access and use the Platform, for the sole purpose of enjoying the Services.‍

1.3 This licence is limited in time to the existence of a current Subscription Period and, geographically, to the territory in which the bank accounts are located.

1.4 In addition, the Purchase Order may establish a certain Perimeter of Use (e.g. bank accounts on which the Client will receive the Services). The Perimeter of Use described in the Purchase Order may only be changed by written agreement of the parties.

1.5 The granting of this licence is subject to the fulfilment by the Client of all its obligations and, in particular, to the payment of the prices indicated in the Purchase Order.

2. Carrying out additional work

2.1 Implementation tasks

2.1.1. In addition to the Services, Embat may, at the Client's request, carry out implementation tasks for access to the Platform in order to adapt the Platform to the Client's technological systems. By way of example, implementation tasks may include integration with devices, systems and other applications used by the Client.

2.1.2 The beginning and duration of the implementation work shall be agreed by the parties. Unless otherwise agreed by the parties, Embat shall not commence implementation work until these services are paid for by the Client. Embat shall use commercially reasonable efforts to complete the implementation work within the agreed timeframe, but the Client understands that deviations from the stated timeframe may occur for reasons related to, but not limited to, the technical requirements of the project or delays by the Client in providing Embat with the information, documentation or permissions necessary to execute the implementation work.

The prices and the invoicing and payment conditions for the implementation tasks are detailed in the Purchase Order.

If the parties have agreed in the Purchase Order that all or part of the cost of the implementation work is to be paid in advance, Embat shall not be obliged to commence such work until it has received the corresponding amounts.

2.2 Systems integration

The Client is informed that in order to provide the Service correctly, it may be necessary to integrate the systems of the Regulated Provider, Embat and the Client. 

In such case, the Parties shall cooperate in good faith during the term of the Agreement to ensure the interoperability of their respective systems and technological means. To this end, the Client shall allow Embat access to the technological means necessary for the proper provision of the Service.

2.3 Alterations to the scope of Services

The scope of the Services may be altered at the request of either party in order to include new services or functionalities, modify or delete any of them, modify the Perimeter of Use, increase the number of Users, etc.

Any alteration in the scope of the Services shall require prior agreement of the parties as to their content, duration and price.

Notwithstanding the foregoing, the express consent of the Client shall not be required where it is necessary for Embat to implement any alteration to the scope of the Service to ensure compliance with applicable regulations, although the Client shall have the right to terminate the Agreement within one month of the implementation of the alteration.

3. Means used for the provision of the Services

3.1 Access to Regulated Providers

3.1.1 Through the Platform, the Client shall have access to various Payment Service Providers with which Embat has entered into an agreement. 

3.1.2 In order for the provision of the Services to be possible, the Client must explicitly consent to the conditions under which the Regulated Provider provides its services.

3.1.3 In the absence of such consent, the provision of the Service by Embat shall not be possible, without any liability for Embat.

3.2 Other means

3.2.1 Embat may provide its Services to the Client by other means. By way of example, when the Regulated Provider does not have the necessary authorisation to provide the Services in a specific territory, the Services may be provided by means of the Client’s incorporation of information files to the Platform, without this ever implying the provision of a regulated service that requires Embat to obtain a licence or administrative authorisation.

3.2.2 Embat may also use various technology providers, such as cloud storage service providers, to provide its Services.

4. Duration

4.1 Unless a different term is expressly stated in the Purchase Order, this Licence Agreement shall enter into force on the commencement date of the Subscription Period and shall remain in force for as long as there is a current Subscription Period. 

4.2 The Subscription Period shall automatically renew for successive periods of the same duration as the Subscription Period, unless either party notifies the other in writing of its desire not to renew the Subscription Period at least thirty (30) days prior to its expiry date.

5. Termination

5.1 This Licence Agreement may be terminated, in addition to the causes provided by law, in any of the following circumstances:

1. Upon non-renewal of the Subscription Period in accordance with the terms described in the preceding clause. 
   

2. When either party is in breach of its obligations, provided that this has been notified by the party in default and has not been remedied within one (1) month of notification. If the non-performance cannot be remedied, the performing party may terminate the Licence Agreement with immediate effect by simple written notice. Among others, an irremediable breach shall be deemed to exist if the Client infringes Embat's intellectual property rights. 

3. Where either party discontinues its business or ceases, for any reason, to provide its main line of business, there is a substantial alteration in the nature of the business, its liquidation or its orderly winding-up or closure.

4. The filing of enforcement proceedings against any of the Parties or the issuance of liens or other measures that reveal financial difficulties for the normal performance of its activities.

5. When, as a result of a merger, spin-off, global transfer of assets and liabilities or sale of a stake in the Client’s capital, the resulting company is controlled by companies that are current or potential competitors of Embat.

5.2 For the causes of termination indicated in clause 6.1 (a), (c), (d) and (e) above, written notice shall be required from the party wishing to request termination, indicating the time from which it wishes termination to take effect.

5.3 The Client may terminate this Licence Agreement unilaterally at any time (provided that the implementation tasks have been completed) without cause by simple written notice. However, unilateral termination without cause shall not release the Client from its obligation to pay Embat the full amounts due until the end of the current Subscription Period, nor shall it be entitled to claim any such amounts from Embat.

5.4 Embat may unilaterally withdraw from the Licence Agreement at any time with a minimum of 1 month's notice, in which case Embat shall reimburse the Client for the proportionate part of the price set in the Purchase Order corresponding to the Services not provided.

5.5 Upon termination of this Licence Agreement, the Client shall automatically lose access to the Platform.

6. Prices and payments

6.1 Prices, invoicing and payment conditions are detailed in the Purchase Order.

6.2 In the event of automatic extension, the prices shall be updated in accordance with the General National Index of the Consumer Price System published by the National Institute of Statistics or equivalent body, taking as a basis the price corresponding to the immediately preceding year ("CPI"). The Parties agree to carry out the revision by comparing the CPI corresponding to the month prior to the date on which the update is to take effect and that of the same month of the previous calendar year. This revision shall not result in a lower price than the price paid in the previous year.

6.3 The prices stated in the Purchase Order do not include, unless expressly stated otherwise, taxes, duties and other applicable charges. Each party shall be responsible for the payment of any levies applicable to it in accordance with the law.

7. Intellectual Property

7.1 Embat owns all intellectual property rights in the Platform and any related elements (e.g. any manuals Embat makes available to the Client for the use of the Platform). This includes, by way of example:

1. All rights to the source code, object code, interface, databases and other elements that make up the Platform.
   

2. All rights to Embat's logos, trademarks, trade names and other distinctive signs.

7.2 Embat shall also own all intellectual property rights in the know-how and results of the work carried out in connection with its relationship with the Client. This includes, by way of example, any developments Embat makes during the performance of the implementation work (or thereafter) to adapt the Platform to the Client’s needs or to integrate the Platform with the devices, systems and other applications used by the Client.

7.3 By taking out a subscription to the Platform, the Client acquires only a right to use the Platform in accordance with the limitations set out in the Perimeter of Use. The right to use the Platform is granted to the Client by licence (not by sale). Accordingly, the Client may not sell, rent, lease, distribute, assign or transfer the Platform in any way to any third party.

7.4 The Client grants Embat a non-exclusive licence to use its trademarks, distinctive signs and trade names free of charge, worldwide and for the duration of this Licence Agreement and any extensions thereto, in order for Embat to provide the Services. Embat may also use the Client’s trademarks and/or distinctive signs in promotional materials, spaces and actions that it may carry out for the purpose of mentioning the Client as one of its clients. This use may be made, among others, in commercial and professional presentations (oral or written, including interviews and reports), websites, social platforms, etc. The Client may object to the use of its distinctive signs by sending a written notification to the email address indicated in the Purchase Order.

8. Obligations of the Client

8.1. In addition to complying with the obligations set out in this Agreement, the Client undertakes to:

1. use the Platform and the access keys to the same in a confidential manner and in accordance with the instructions for use, security and proper functioning received from Embat, as well as to enforce this obligation on Users;
   

2. immediately notify Embat of any unauthorised access to the Platform;

3. ensure that the Platform is compatible with your systems and equipment, network connections and telecommunications links;

4. that the maximum number of Users does not exceed the number set out in the Purchase Order;

5. expressly consent to the Regulated Provider in order for Embat to perform the Services that are the subject of this Licence Agreement;

6. ensure the accuracy, completeness and legality of any data, information or material provided by the Client or any User and obtain consents and authorisations for the Client to enter such data on the Platform; and

7. provide Embat with the information necessary for the performance of its obligations under this Licence Agreement
   

9. Embat's obligations

1. For its part, in addition to taking all actions provided for in this Licence Agreement, Embat undertakes to:
2. to have the human resources and technological means necessary for the correct provision of the Services;
3. notify the Client in advance of any variations or alterations in the current regulatory and technological framework which are beyond Embat's control and which may affect the operation of the Platform;

1. have such permissions, licences (including software licences) and authorisations as are necessary for the proper execution of this Licence Agreement; and

10. Non-permitted uses of the Platform

10.1 The Customer must use the Platform or any other related element for finance planning and treasury management only.

10.2 In addition to the performance of its obligations under this Licence Agreement and applicable law, the Client undertakes to:

1. Not to provide third parties with access to the Platform or the information contained therein, except as expressly provided for in this Licence Agreement.
2. Do not use the Platform to transmit or install viruses or other harmful elements.
3. Do not attempt to access restricted sections of the Platform or its systems and networks.
4. Do not attempt to breach the Platform's security or authentication measures.
5. Not to modify, replicate, reverse engineer, decompile the Platform code, except where expressly authorised by law.
6. Not to interfere with the performance of the Platform and, in particular, not to misuse the Platform so as to cause it to become saturated.
7. Not to use the Platform for the purpose of extracting information that would enable you to offer a product or service (analogue or digital) that competes with the Platform.
8. Not to use the Platform or any other related element in a way that violates applicable law.

11. Restriction of access to the Platform

11.1 Embat reserves the right, at its sole discretion and without liability, to temporarily or permanently suspend the Client’s access to the Platform (in whole or in part) in the event of any of the following circumstances:

1. In the event of scheduled or emergency maintenance of the Platform, Embat shall communicate in advance the time and estimated duration of the scheduled maintenance work.
2. In the event that Embat reasonably suspects that the Client’s use of the Platform violates this Licence Agreement, applicable law or poses a security risk to Embat or a third party.
3. If required by a competent authority.
4. In the event that the Client fails to meet its commitments and, in particular, its payment obligations.

11.2 The foregoing is without prejudice to any other rights Embat may have under law or this Licence Agreement, including Embat's right to terminate this Licence Agreement on the terms described in clause 5.

12. Confidentiality

12.1 During the term of this Licence Agreement the parties may share Confidential Information.

12.2 Unless otherwise expressly authorised by the party disclosing the Confidential Information, the party receiving the Confidential Information shall: (i) keep the Confidential Information secret, (ii) not reproduce it, (iii) diligently guard it, applying the same level of diligence with which it protects its own Confidential Information (provided that this level of diligence is reasonable and sufficient), (iv) share it only with those employees or collaborators who need to know it and not communicate it to any other third party, (v) use the Confidential Information only for such purposes as are strictly necessary to comply with this Licence Agreement, and (vi) promptly comply with any request from the party disclosing the Confidential Information for its return or destruction (except where such Confidential Information is required to be retained for legal reasons).

12.3 The parties shall impose these obligations of confidentiality on their employees and collaborators.

12.4 For the avoidance of doubt, the Client accepts that the economic conditions agreed in the Purchase Order are considered Confidential Information (whereby, inter alia, the Client may not communicate the fees agreed with Embat to any third party).

12.5 The parties shall not be subject to the obligation of confidentiality regulated in this clause when Confidential Information must be disclosed by law or to comply with an order of a judicial or administrative nature, provided that they notify without undue delay - to the extent legally possible - the party to whom the Confidential Information pertains.

12.6 The confidentiality obligations shall apply during the term of this Licence Agreement and even after its termination for any reason whatsoever.

13. Data protection

13.1 The personal data of the natural persons (signatories and/or interlocutors) involved in the acceptance of these Terms and Conditions, as well as of the Purchase Order, will be processed by Embat Technologies, S.L. (whose data appear in the heading of this license agreement) for the proper management of the contracted services, including user management, resolution of technical incidents or doubts about platform, as well as administrative, economic and accounting management, being the legitimizing basis the execution of a contract in accordance with the provisions of Article 6.1.b of the RGPD, so that the failure to provide personal data could result in the impossibility of the execution of the license agreement. 

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Personal data will be retained for the time necessary to give due satisfaction to the provision of contracted services. When they are no longer necessary, they will be kept for as long as it is necessary to keep them in accordance with a legal obligation and/or in order to meet possible liabilities arising from the processing.

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In general, we do not share your data with third parties, except in compliance with a legal obligation. However, for an optimal provision of the service that Embat provides, it may require third party service providers trusted by Embat to access the User's personal data as data processors, under its control and to the extent strictly necessary for the provision of the services contracted with them. Such processors operate under a service contract under the terms, conditions and guarantees contained in the General Data Protection Regulation, Embat performing the corresponding controls, inspections and audits in this area to verify that such processors strictly comply with the contracts signed for this purpose and the applicable regulations.

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Users understand that some of the aforementioned service providers are located in, or access data from, countries outside the European Economic Area (EEA) and therefore do not offer the same level of personal data protection as in the EEA, such as the United States, United Kingdom, Switzerland, Canada, Colombia, Brazil, New Zealand, Singapore, Japan and Australia. In any case, Embat guarantees that it has adopted the appropriate measures and safeguards established in this area in accordance with the European Personal Data Protection Regulation, including the data transfer agreements based on the Standard Contractual Clauses approved by the European Commission dated June 4, 2021 (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021D0914), as well as, in the cases of the UK, Switzerland, Canada, New Zealand, Japan and the USA (for those entities adhered), under the Commission's adequacy Decisions which have declared that such third countries offer an adequate level of protection. More information on international data transfers can be found at the following link https://www.aepd.es/en/rights-and-duties/fulfill-your-duties/measures-compliance/international-data-flows or by writing to legal@embat.io. 

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At any time, data subjects may exercise their rights of access, rectification, erasure, objection and restriction of processing, as well as portability of their personal data, in accordance with the General Data Protection Regulation, by writing to the postal and/or e-mail address indicated in the heading of this license agreement (legal@embat.io). In particular, they are informed of their right to file a complaint with the Spanish Data Protection Authority (www.aepd.es) if they consider that the processing does not comply with the regulations in force or if they have not obtained satisfaction in the exercise of their rights.

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13.2 The processing of personal data carried out by Embat derived from the provision of the services included in this License Agreement shall be governed by the provisions of this clause, by the provisions of the Privacy Policy available on the website, as well as, if applicable, by the data processing agreement available as an annex to this license agreement.

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You can find Embat's processing order agreement here.

14. Representations and responsibilities of the Client

14.1 The Client acknowledges that the Platform has not been designed and adapted to meet the Client's individual requirements. It is the Client’s responsibility to ensure that the operational and technical characteristics of the Platform meet its needs before placing the Purchase Order.

14.2 The Client is responsible for any aspect of the information included on the Platform by itself or the Users and warrants that: (a) it does not infringe applicable law or the industrial property rights, intellectual property rights or any other rights of third parties; and (b) it does not contain or transmit viruses or other harmful elements.  

14.2.1 If the Client contracts the provision of implementation services with a third party other than Embat, Embat shall not be liable for the provision of such services by such third party, including in terms of the quality of the work performed, diligence, results and, in particular, the fees payable to such third party.

14.3 The Client shall indemnify Embat against any damages, losses, claims, costs or expenses that Embat may suffer as a result of: (i) the Customer's or Users' use of the Platform (including, without limitation, any misuse which may result in the loss of passwords, system hacks, the making of improper payments or payments to accounts or recipients other than those to whom they should be made, the making of transactions in restricted jurisdictions or the failure to comply with applicable regulations - and, in particular, applicable money laundering and terrorist financing regulations); (ii) a breach (by either the Customer or the Users) of its obligations under this Licence Agreement and applicable law.

14.4 Without prejudice to the foregoing, the Client shall in no event be liable for indirect damage, loss of profit, loss of data, loss of information, loss of profit or for any special category of damage caused to the Client or third parties.

15. Embat's representations and responsibilities

15.1 Embat warrants that it owns all intellectual and industrial property rights in the Platform to the extent necessary to grant the licences governed by this Licence Agreement.

15.2 Although Embat takes reasonable steps to ensure the proper functioning of the Platform, Embat represents and the Client agrees that the Platform is provided "as is" and "as available" without express or implied warranties of any kind. Among other things, Embat shall not be liable for any damages that the Client or any third party may suffer as a result of:

1. The inadequacy of the Platform.
2. Lack of accessibility, availability, usability or performance of the Platform.
3. Errors or lack of accuracy or quality of the data and information contained in the Platform.
4. Unlawful interference by a third party or the introduction of viruses into the Client’s user account or computer systems.
5. Lack of compatibility between the Platform and the devices or networks that the Client uses to access them.

15.3 Under no circumstances shall Embat assume any liability to the Client for any liability that may arise from the provision of services by Regulated Providers or Technology Providers, or for any faults, defects or errors arising from the results obtained from the services contracted with these third parties.

15.4 Embat shall also not be liable for the availability of the services provided by Regulated Providers or Technology Providers.

15.5 If, at any time, Embat becomes aware that the Platform or its use in accordance with this Licence Agreement infringes or may infringe any third party rights or applicable law, Embat may choose to: (i) modify, at its own expense, all or part of the Platform in order to avoid the infringement; (ii) acquire, at its own expense, the licences necessary to avoid the infringement; or (iii) terminate this Licence Agreement. If the modification or termination of the Licence Agreement pursuant to (i) and (iii) above would cause damage to the Client, the Client shall be entitled to a pro rata refund of the amount paid for the Platform. In the event of any of these circumstances, Embat will contact the Client as soon as possible in order for the Client to delete, if necessary, any copies of the Platform that the Client has stored on its systems. 

15.6 Embat shall in no event be liable for indirect damages, administrative penalties, loss of profit, loss of data, loss of information, loss of profit or for any special category of damage caused to the Client or third parties.

15.7 Embat's total and aggregate liability to the Client and third parties arising under this Licence Agreement shall be limited to the amount actually paid by the Client to Embat for the Platform in the six (6) months immediately preceding the occurrence of the event giving rise to the claim. 

15.8 The limitation set out above shall not apply in the event of Embat's wilful misconduct. Similarly, where applicable law does not permit the exclusion or limitation of Embat's liability under the terms of this clause, Embat's liability shall be excluded and limited to the extent permitted by law.

16. Assignment and subcontracting

16.1 The parties may not assign their rights and obligations under this Licence Agreement without the prior written consent of the other party. However, the parties need not seek the other party's consent (but must inform the other party) if the assignment is to an entity that is part of the same business group or to a third party that acquires all or a substantial part of the other party's shares, assets or business.

16.2 Embat may subcontract the provision of all or part of the services related to the Platform.

17. Notifications

17.1 All communications between the parties relating to the Licence Agreement shall be in writing, whether by post, bureaufax or e-mail sent to the addresses indicated in the Purchase Order. Communications made by letter with acknowledgement of receipt and those made by telegram, bureaufax or e-mail shall be deemed to have been duly delivered and received when their receipt can be proved.

17.2 The parties shall immediately communicate any changes in their contact addresses.

18. Modifications to the Platform

18.1 Embat reserves the right, at any time and without prior notice, to make improvements, replacements or other modifications to any functionality or content of the Platform. Such changes may be made for a variety of reasons, including Embat's desire to increase the capabilities of the Platform, the need to comply with regulatory requirements, or to ensure the compatibility of the Platform with new standards.

18.2 Under no circumstances shall Embat be deemed to be in breach when the modifications to the Platform are beyond Embat's control and affect the operation of the Platform, even to the extent of partially or totally disabling its use. In such circumstances, Embat cannot guarantee the use or correct functioning of the Platform and therefore does not assume any obligation in this respect or any liability for any contingency that may arise from these causes.

19. Miscellaneous

19.1 Independence of the parties. The parties act on their own account and as independent contractors. Nothing in this Licence Agreement shall be construed as creating between the parties (or between them and their employees or representatives) an employment relationship or business association of any kind (joint venture, franchise, agency, joint venture, etc.).

19.2 Integrity. Unless we have entered into a separate agreement, this License Agreement sets forth the rules governing the provision of the Services and constitutes the entire agreement of the parties, and supersedes all other agreements, negotiations, and any other communications, oral or written, existing up to the date of signing this License Agreement.

19.3 Preservation. In the event that any provision of this License Agreement is declared null and void, in whole or in part, such nullity shall not affect the validity of the remainder of this License Agreement and such provisions shall remain in full force and effect.

19.4 Waiver. The failure of either party to exercise or enforce any right or provision of this License Agreement shall not constitute a waiver thereof, unless acknowledged and agreed to in writing by you.

19.5 Prevailing Language. The original version of this Licence Agreement has been drafted in English. The English version of this Licence Agreement shall prevail in the event of any conflict with any other version that Embat may provide to Client as a courtesy (including the English version). 

19.6 Updating the Licence Agreement. Embat reserves the right to update this License Agreement from time to time as it deems appropriate (including, but not limited to, to adapt to regulatory changes and to provide the Client with a better service). It is the Client's responsibility to periodically review this License Agreement. If the Client continues to use the Platform following a modification to this Licence Agreement, the Client shall be deemed to have expressly and unreservedly accepted such modification. In the event that the Client does not accept a modification to the Licence Agreement, the Client may not continue to use the Platform.

20. Jurisdiction and applicable law

20.1 This License Agreement is governed by Spanish law.

20.2 The parties, expressly waiving any other jurisdiction, agree to submit disputes relating to this Licence Agreement to the exclusive jurisdiction of the judges and courts of the municipality of the city of Madrid.

21. Definitions

21.1 "Licence Agreement" means this agreement setting out the terms and conditions under which Embat will provide financial planning and treasury management services to businesses on a SaaS (software as a service) basis.

21.2 "Embat" refers to EMBAT TECHNOLOGIES, S.L., a company with registered offices at Calle de Fuencarral, 123 - 5A, Madrid, 28010, Madrid, whose Tax Identification Number is B16808693.

21.3 "Platform" means the technological infrastructure developed by Embat for the provision of financial planning and treasury management services on a SaaS (software as a service) basis.

21.4 "Client" means the company or entity that contracts a subscription to the Platform and whose identification details are set out in the Purchase Order. 

21.5 "Regulated Provider" means the various providers providing account information aggregation and payment initiation services on the basis of the relevant licences and administrative authorisations to which the Client would have access through the Platform.

21.6 "Technology Provider" means the various technology service providers Embat may use to provide the Services. 

21.7 "Purchase Order" means the document by which the Client and Embat formalise the purchase of a subscription to the Platform. The Purchase Order details aspects such as the Client’s identification data, the price of the subscription, etc. 

21.8 "Perimeter of Use" refers to the scope of the licence to use the Platform contracted by the Client (e.g.: the perimeter of group companies and bank accounts on which the Client will receive the services). If the Perimeter of Use is limited, this must be expressly stated in the Purchase Order.

21.9 "Subscription Period" means the period of the duration of the licence to use the Platform contracted by the Client.

21.10 "Services" refers to financial planning and treasury management services provided to businesses on a SaaS (software as a service) basis. 

21.11 "Confidential Information" means all information of any nature (technological, scientific, industrial, commercial, organisational, financial, etc.) communicated by one party to the other in connection with this Licence Agreement, irrespective of the medium used for its disclosure (oral, written, etc.). 

21.12 "Users" means natural persons (employees, representatives, managers, shareholders, consultants or agents) accessing the Platform on behalf of the Client.

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Last updated: May 2024